Medway Local Plan (Regulation 18, 2023)

Vision

Redrow, who has an interest in land to the west of Pump Lane, Rainham (RN9), fully support the Vision and recognise that the countryside, coast and the urban open spaces are valued and benefit as joined up environmental assets in a resilient green infrastructure network. Important wildlife and heritage assets are protected and enhanced. Medway has transitioned to a low carbon economy, with a clear path mapped out to reaching ‘net zero’. Development brought forward by Redrow, on a series of sites, can contribute to the Vision.

It is considered that green growth can and should be supported across the Borough and this should be inclusive of delivering the new homes required. Redrow believe that suburban expansion at Rainham is one way to sensitively deliver homes where they are needed, whilst still protecting and enhancing valued heritage and environmental assets. These should be embraced and incorporated within well designed development, rather than being seen or used as constraints to development at locations where development could be sustainable.

Redrow support the scope for improved travel choices and infrastructure that can reduce use of the private car across Medway, with people benefitting from better provision for pedestrians and cyclists, and a greater public transport offer. This has already transformed how people move through the central urban areas and strengthened the connections with wider neighbourhoods and villages and, looking forward, will be means to mitigate and alleviate against existing highway capacity constraints.

These transport initiatives can and should be incorporated into new development on the edges of the suburban areas, such as at Rainham, to deliver the growth required in a sustainable way and the Local Plan is the way to achieve that. This may include wider strategic planning and masterplanning to enable an integrated approach across a range of sites located at the edge of the main suburban area. While some sites could come forward on their own, such masterplanning could look to integrate and co-ordinate the delivery of wider transport initiatives, together with the provision of social infrastructure and green infrastructure required, while enhancing local heritage and landscape assets.

Strategic Objectives

As stated above, Redrow support the objective to strengthen and develop transport networks to provide safe and effective choices for sustainable travel, including improved opportunities for walking and cycling and enhanced public transport services, and management of the highways network, with associated improvements in air quality. This is seen as key to unlocking development potential at sites where, historically, highway capacity has been seen as a constraint.

Further, Redrow recognise the need to secure a robust green and blue infrastructure network across land and water that protects and enhances the assets of the natural and historic environments in urban and rural Medway; providing resilience for nature through better connectivity and conditions; informing the design and sustainability of new development; and supporting healthier lifestyles.
These can readily be incorporated into development proposals and it is considered that these can best be planned in co-ordination with a growth strategy to deliver the new homes required at the appropriate location. The Local Plan could set out a clear strategy for achieving these objectives within individual site allocations but also across a wider area, such as suburban expansion at Rainham, through masterplanning and co-ordination of development proposals (a Framework).

New housing growth in selected areas can also achieve the objective to reduce inequalities in health by delivering better outcomes for residents, by promoting opportunities for increasing physical activity and mental wellbeing, through green infrastructure and public realm design for walking, cycling, parks and other recreation facilities.

Well designed and co-ordinated new housing growth at the right suburban locations could reduce social isolation by supporting retention and enhancement of local services close to where people live, and inclusive environments that are accessible by all groups in society. It could also strengthen the role of Medway’s existing urban, neighbourhood and village centres, responding with a positive strategy to changes in retail; supporting independent retail and start-ups, encouraging new business uses into the High Street. It would help to secure a range of accessible services and facilities for local communities close to where they live.

As set out above, Redrow support the objective to boost pride in Medway through quality and resilient development, and this could be achieved with development that is supported by and co-ordinated with the timely provision of good quality effective infrastructure, so that the needs of Medway’s growing and changing communities are well served. As such, it is critical to deliver sustainable development, meeting the needs of Medway’s communities, respecting the natural and historic environment, and directing growth to the most accessible locations, which should include suburban extensions, to best enhance Medway’s existing economic, social and environmental characteristics.

Strategic Objectives

As stated above, Redrow support the objective to strengthen and develop transport networks to provide safe and effective choices for sustainable travel, including improved opportunities for walking and cycling and enhanced public transport services, and management of the highways network, with associated improvements in air quality. This is seen as key to unlocking development potential at sites where, historically, highway capacity has been seen as a constraint.

Further, Redrow recognise the need to secure a robust green and blue infrastructure network across land and water that protects and enhances the assets of the natural and historic environments in urban and rural Medway; providing resilience for nature through better connectivity and conditions; informing the design and sustainability of new development; and supporting healthier lifestyles.
These can readily be incorporated into development proposals and it is considered that these can best be planned in co-ordination with a growth strategy to deliver the new homes required at the appropriate location. The Local Plan could set out a clear strategy for achieving these objectives within individual site allocations but also across a wider area, such as suburban expansion at Rainham, through masterplanning and co-ordination of development proposals (a Framework).

New housing growth in selected areas can also achieve the objective to reduce inequalities in health by delivering better outcomes for residents, by promoting opportunities for increasing physical activity and mental wellbeing, through green infrastructure and public realm design for walking, cycling, parks and other recreation facilities.

Well designed and co-ordinated new housing growth at the right suburban locations could reduce social isolation by supporting retention and enhancement of local services close to where people live, and inclusive environments that are accessible by all groups in society. It could also strengthen the role of Medway’s existing urban, neighbourhood and village centres, responding with a positive strategy to changes in retail; supporting independent retail and start-ups, encouraging new business uses into the High Street. It would help to secure a range of accessible services and facilities for local communities close to where they live.

As set out above, Redrow support the objective to boost pride in Medway through quality and resilient development, and this could be achieved with development that is supported by and co-ordinated with the timely provision of good quality effective infrastructure, so that the needs of Medway’s growing and changing communities are well served. As such, it is critical to deliver sustainable development, meeting the needs of Medway’s communities, respecting the natural and historic environment, and directing growth to the most accessible locations, which should include suburban extensions, to best enhance Medway’s existing economic, social and environmental characteristics.

Strategic Objectives

As stated above, Redrow support the objective to strengthen and develop transport networks to provide safe and effective choices for sustainable travel, including improved opportunities for walking and cycling and enhanced public transport services, and management of the highways network, with associated improvements in air quality. This is seen as key to unlocking development potential at sites where, historically, highway capacity has been seen as a constraint.

Further, Redrow recognise the need to secure a robust green and blue infrastructure network across land and water that protects and enhances the assets of the natural and historic environments in urban and rural Medway; providing resilience for nature through better connectivity and conditions; informing the design and sustainability of new development; and supporting healthier lifestyles.
These can readily be incorporated into development proposals and it is considered that these can best be planned in co-ordination with a growth strategy to deliver the new homes required at the appropriate location. The Local Plan could set out a clear strategy for achieving these objectives within individual site allocations but also across a wider area, such as suburban expansion at Rainham, through masterplanning and co-ordination of development proposals (a Framework).

New housing growth in selected areas can also achieve the objective to reduce inequalities in health by delivering better outcomes for residents, by promoting opportunities for increasing physical activity and mental wellbeing, through green infrastructure and public realm design for walking, cycling, parks and other recreation facilities.

Well designed and co-ordinated new housing growth at the right suburban locations could reduce social isolation by supporting retention and enhancement of local services close to where people live, and inclusive environments that are accessible by all groups in society. It could also strengthen the role of Medway’s existing urban, neighbourhood and village centres, responding with a positive strategy to changes in retail; supporting independent retail and start-ups, encouraging new business uses into the High Street. It would help to secure a range of accessible services and facilities for local communities close to where they live.

As set out above, Redrow support the objective to boost pride in Medway through quality and resilient development, and this could be achieved with development that is supported by and co-ordinated with the timely provision of good quality effective infrastructure, so that the needs of Medway’s growing and changing communities are well served. As such, it is critical to deliver sustainable development, meeting the needs of Medway’s communities, respecting the natural and historic environment, and directing growth to the most accessible locations, which should include suburban extensions, to best enhance Medway’s existing economic, social and environmental characteristics.

Spatial Strategy

Redrow would strongly encourage Medway to prepare a Local Plan that seeks to deliver the homes required, as derived by the standard method. As indicated in the Regulation 18 draft Local Plan, the Government considers that this method is appropriate to meet its housebuilding ambitions to tackle pressures in the housing market and there is a housing crisis, particularly regarding affordability. There is an absolute need to deliver the homes required when and where they are needed to meet Medway’s growing needs and the requirements for those desperately needing a good quality home. The Local Plan must set out a strategy to achieve this. This requires a wide range of sustainable housing allocations at different scales and locations that can be delivered at different rates and times.
Redrow would agree that consideration should be given to potential impacts on the environment and strategic infrastructure needs. However, these should not simply be seen as a constraint to new housing growth as the focus should be to assess how negative impacts could be avoided, or mitigated, such as through the co-ordinated delivery of new services and enhancements to landscapes, heritage and biodiversity.

Urban sites will have an important role to play, but they are not always available and will often deliver the smaller homes (1 and 2 bed flats), with less affordable housing as demolition, conversion or land decontamination is often required and, as such, development of such sites tends to have higher costs for these reasons. As the Regulation 18 Plan recognises, this can affect viability and hence the type of development that can be delivered and when it is delivered.

On the other hand, suburban expansion sites are located in close proximity to the urban areas, are usually available and can deliver larger family homes with policy compliant affordable housing. There are potential environmental impacts but this can be mitigated through careful layout and design.

Redrow would agree that development on the green field sites in this category would be expected to be built quicker as the site constraints are more limited than brownfield sites. It is also recognised that development of large sites in this location, or smaller sites that are comprehensively planned, could provide opportunities to enhance sustainable travel options, making it easier and more attractive for people to walk, cycle and use public transport. New housing in these locations could support existing services and facilities and deliver more if required.

It is noted that development to the east of Rainham would erode the strategic gap between Rainham and Newington and add further to the congestion and pollution issues on the A2 and that larger scale development would not be appropriate to the south, around the Capstone Valley as this would potentially adjoin the development of the proposed ‘Lidsing Garden Community’ in Maidstone. As such, there should be more focus on the potential land to the north of Rainham, with detailed consideration given and discussions held with land owners to identify how potential impacts could be appropriately mitigated and integrated development secured.

Land to west of Pump Lane, Rainham

As stated above, Redrow has an interest in approximately 24Ha of land to the west of Pump Lane, Rainham (SLAA site: RN9).
It is considered that the land has good potential as an accessible, suburban expansion site, to deliver sustainable housing development that would accord with the draft Local Plan’s Vision and Objectives. There will be some constraints to development that need to be overcome/mitigated, but that is likely to be the case, in some form or other, across the Medway Council area. In this case, it is considered that these constraints could be appropriately addressed, through well considered proposals and a criteria-based allocations, for the reasons set out below.

A high-level illustrative layout, demonstrating how a scheme could come forward at land to the west of Pump Lane, has been appended to this representation.

Availability

As Redrow have an interest in the land and are promoting the site for residential development on behalf of the landowner, we can confirm that the land is available for early delivery. Redrow would be keen to engage with officers to discuss how this land could deliver new homes in the shorter term, while mitigating environmental and heritage impacts. In the Local Plan, these could be covered by a criteria-based policy linked to an allocation of the land for housing.

Addressing Potential Constraints

Redrow are aware of the appeal decision on this site (ref. APP/A2280/W/20/3259868) - the appeal site measured approximately 50Ha, whereas Redrow’s proposed allocation is only half of this, at 24Ha.Redrow are also aware of the concerns raised in the Reg 18 draft Local Plan regarding potential development in this broad area. However, it is considered that a carefully and sensitively design scheme could address the highway capacity issues and the harms identified by the Inspector.

Highway Capacity, Sustainable Transport and Access

The appeal inspector found that the residual cumulative impacts on subnetworks 3 and 7 would not be severe, but that is not the case for subnetwork 2. The residual cumulative impacts on that subnetwork would, in her view, be severe, particularly during both the AM and PM peaks. She recognised that those impacts would be confined largely to the peak hours and that the subnetwork forms only a part of the wider network.

A Transport Technical Note (TTN) has been prepared in support of these representations. The TTN outlines the multi-modal access strategy that could be achieved should a planning application come forward on this site; considers the accessibility of the site; quantifies the likely vehicular trip generation of the proposed development; and identifies appropriate and proportionate mitigation measures. In doing so, it addresses the reasons for refusal of the previous planning application and appeal concerning the wider landholding of relevance to highways and transportation.

The vehicular trip generation and distribution exercise presented below confirms that the impact of the proposals in this regard would be much-reduced relative to the previous scheme. It is further demonstrated that ongoing shifts in travel behaviour away from traditional peak period commuting, together with both ‘soft’ and ‘hard’ travel planning measures and ‘decide and provide’ mitigation strategies, will ensure that there would be no ‘severe’ residual highways impacts, in accordance with Paragraph 111 of the National Planning Policy Framework.

The note concludes the site represents a viable and sustainable location for development in transport planning terms and that the highways reasons for refusal of the previous outline planning application can be overcome.

Landscape

The site forms part of the Gillingham Riverside Area of Local Landscape Importance (ALLI). The area is characterised by scattered dwellings/clusters of dwellings, as well as the small hamlet of Lower Twydall, which sits to the west of the site, with the small village of Lower Rainham, which straddles the Lower Rainham Road to the northeast. Both settlements are designated Conservation Areas. Beyond the railway line, to the southwest, is the urban settlement of Twydall/Rainham with shops, services and good public transport links. To the north, east and west, the site is surrounded by agricultural land which extends up to the Medway Estuary. The Medway Landscape Character Assessment (MLCA) recognises that the Lower Rainham Farmland Character Area (LRFCA) identifies the area has value as an extended buffer to the Country Park and protected Estuary coastline, which lie to the north.

The Planning Inspector regarded the change in character as ‘distinct and abrupt’, as opposed to it being an area of ‘transition’ between town and country. The Inspector also noted that the development would, as a matter of fact, comprise a ‘significant and large scale development’. As such, she was of the view that the development proposed would be uncharacteristic and of a significant scale.
However, the Inspector noted that the site is generally well contained by mature vegetation, including woodland and tall hedgerows, limiting available views and extent of visibility. She also noted that the landscape effects would be experienced from a relatively constrained area around the site. It would, therefore, be possible to reduce the impact on the landscape with a less significant scheme for the site, that was designed to be more transitional - with pockets of development with an enhanced framework of landscaped breaks and buffers. A landscape led proposal (as shown on the attached plan appended to this representation) for the site could provide an attractive setting to the Lower Rainham and Lower Twydall Conservation Areas, with attractive views from the river and railway, forming a green backdrop in views from the Estuary.


Pump Lane

As an additional concern, the Inspector noted is that Pump Lane is an unlit, narrow, sometimes single-track country lane with no footways. Towards its northern end, it is fronted on one side by a small group of dwellings, but for the most part, it is lined along both sides with mature hedges/hedgebanks. She added that it is identified as a rural lane by policy BNE47 which, among other things, seeks to protect the landscape value of such lanes.

The Inspector went on to note that, for the appeal proposal, four new junctions were proposed on Pump Lane to facilitate its crossing by the proposed estate loop road and, in total, the new junctions on Pump Lane would require the removal of around 175m of hedgerow. The layout of the southern junctions would require any replacement planting to be set back significantly to allow for forward visibility and, at that point, the lane would cease to be narrow and it would no longer be enclosed by hedgerows. She therefore concluded that the highway would have the character and appearance of a residential access road, as opposed to a rural country lane.
However, on review of access proposals to the land, it is considered that there only needs to be a relatively small incursion on Pump Lane, at the southern end, to allow for emergency access, pedestrians and cycles to access the facilities to the south of the railway line. As such, that should not be a constraint to development and should be regarded as a benefit.

Heritage

The Inspector considered the extent of the development proposed would effectively subsume the village of Lower Rainham, and its Conservation Area, into the extended urban area of Twydall/Rainham, with the consequence that it would lose its separate identity and character as a rural village.

The Inspector found that there would be harm towards the middle of the less than substantial range to the special interest and significance of the grade II listed Chapel House, and to the heritage significance of Lower Rainham Conservation Area, with harm identified to other of the designated assets to be at the lower end of the scale. Any harm to the significance of the non-designated Bloors Oasts would be very minor.

Overall, the Inspector concluded that the very substantial benefits that would arise from the appeal scheme, primarily the delivery of much needed new homes, to be sufficient to outweigh the heritage harm identified both individually and collectively. A smaller, well design scheme could avoid any heritage harm.

Conclusion

Overall, it is proposed that a high quality, sustainable housing scheme, delivering policy compliant affordable and family housing to meet short term needs, that would meet the Vision and Objectives for the Local Plan could be achieved on land to the west of Pump Lane, Rainham.

We trust that these representations will assist in ensuring sustainable and deliverable development within Medway to help meet the Council’s vision and strategic objectives as set out in the Regulation 18 Local Plan.